Italy: Guidance on cooperative compliance regime

A voluntary arrangement between the tax authority and taxpayers intended to incentivize transparency and tax compliance.

Guidance on cooperative compliance regime

Pursuant to Law no. 111 of 2023, which directs the government to reform the tax system and became effective August 29, 2023 (read TaxNewsFlash), the government issued Legislative Decree no. 21 (effective January 18, 2024) to reinforce the “cooperative compliance regime” (CCR)—a voluntary arrangement between the tax authority and taxpayers intended to incentivize transparency and tax compliance through continuous and preemptive dialogue.

The decree lowers the CCR entry threshold in stages from €750 million in turnover in 2024 to €100 in turnover in 2028 and reduces for taxpayers who adhere to the CCR by two years (three years under certain conditions) the statute of limitations for the assessment of taxes. The decree also extends certain benefits to taxpayers that voluntarily adopt a “tax control framework” (TCF) and cooperate with the tax authority even if they do not meet the CCR entry thresholds.

Read a June 2024 report prepared by the KPMG member firm in Italy

 

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